Memorandum Opinion and Order — United States v. Aaron Alex Mitchell, No. 1:23-mj-157

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Memorandum Opinion and Order in United States v. Aaron Alex Mitchell, Criminal Action No. 1:23-mj-157 (RDA), in the U.S. District Court for the Eastern District of Virginia, Alexandria Division, filed August 23, 2023 as Document 27. It addresses the government's Emergency Motion for Stay and Appeal (Dkt. 19) of a magistrate judge's Order Setting Conditions of Release (Dkt. 14). The Court states that Defendant has not rebutted the presumption of dangerousness and that the government has established risk of flight by a preponderance of the evidence under the 18 U.S.C. § 3142(g) factors. It orders the motion granted, the release order revoked, and Aaron Alex Mitchell detained pending trial.

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Case 1:23-mj-00157-IDD-RDA Document 27 Filed 08/23/23 Page 1 of 13 PagelD# 127

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA

Alexandria Division
UNITED STATES OF AMERICA )
)
Vv. ) Criminal Action No. 1:23-mj-157 (RDA)

)

AARON ALEX MITCHELL, )
)

Defendant. )

MEMORANDUM OPINION AND ORDER

This matter comes before the Court on the government’s Emergency Motion for Stay and
Appeal (Dkt. 19) of United States Magistrate Judge Ivan D. Davis’ Order Setting Conditions of
Release as to Defendant Aaron Alex Mitchell (Dkt. 14). Defendant has filed an Opposition. Dkt.
23. Considering the Motion, Defendant’s Opposition, as well as the arguments raised by counsel
at the hearing held before this Court on August 23, 2023, this Court GRANTS the Government’s
Motion and REVOKES the Order Setting Conditions of Release for the reasons that follow.

I. FACTUAL AND PROCEDURAL BACKGROUND

Defendant is 38-years old and resides in Phoenix, Arizona. Based on the information that
Defendant has provided to pretrial services, Defendant has been a resident of Arizona for twelve
years. However, Defendant has resided at his current residence for approximately two months
and, when asked by pretrial services, could not recall his current address. Defendant has no family
in the United States; Defendant’s father, sisters, and one brother all reside in Jamaica. Defendant’s
other brother lives in Japan.

Defendant informed pretrial services that he had a valid U.S. Passport and that his only
foreign travel within the past 10 years was to Jamaica for his mother’s funeral. Since that

interview, it has been determined that Defendant also has a Jamaican Passport and a U.S. Passport
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card.' Defendant now also concedes that he has traveled to Mexico on at least two occasions in
2022, although the government proffers that Defendant has made multiple border crossings into
Mexico, including two occasions in 2023.

Defendant informed pretrial services that he lost his employment during the pandemic and
that he remains unemployed outside of “side jobs” that he performs. Defendant reports that he
receives $3000 a month of income from his side jobs. Defendant does not know his rent payment.
The government proffers that Defendant’s income is sometimes as much as $25,000 a month.
Defendant admits to being a daily marijuana user and a cocaine user. Defendant also reports
owning a firearm.

As part of its investigation of a drug trafficking conspiracy, law enforcement identified
packages being sent from Arizona to Northern Virginia as containing illegal drugs. An alleged
coconspirator, who was arrested in March 2023, identified Defendant as the source of supply that
has been mailing fake oxycodone pills from Arizona to this District. 8.14.23 Hrg. Tr. at 22:14-20.
A review of that coconspirator’s cellphone revealed messages with pictures of what appears to be
illegal drugs and messages discussing shipments of packages from Arizona to this District from a
number believed to be used by Defendant. Dkt. 2 914. Defendant was also observed, via United
States Postal Services (“USPS”) security footage mail, mailing a package that was later intercepted
and determined to contain over a kilogram of fake oxycodone pills. 8.14.23 Hrg. Tr. at 15:3-16:1.

On August 10, 2023, law enforcement executed a federal search warrant on a location that
they had been surveilling and arrested Defendant and another alleged coconspirator inside. Law

enforcement also located over 50,000 suspected fake oxycodone pills, 2 kilograms of suspected

' Atthe August 23, 2023 hearing, there was a dispute regarding where the Passport Card is located. Defendant
contends that it is in the possession of the government because it was in his wallet at the time of his arrest. The
government has proffered that it does not believe that Defendant’s wallet was seized and that the government does not
believe that the Passport Card is in its possession.

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fentanyl powder, 1.5 kilograms of suspected cocaine, and a bulk amount of marijuana as well as
firearms. 814.23 Hrg. Tr. at 8:23-9:4. Law enforcement described that, when Defendant was
arrested, Defendant appeared to be reaching for a firearm that was hidden beneath a couch cushion.
Id. at 9:8-10:2.

That same day, Defendant was charged by Criminal Complaint with one count of
conspiracy to distribute 400 grams or more of a mixture and substance containing fentanyl, in
violation of 21 U.S.C. §§ 841(a)(1) and 846. Dkt. 1. On August 14, 2023, the parties appeared
before Judge Davis. See Dkt. 13 (Minute Entry). After a hearing, Judge Davis ordered that
Defendant be released on a personal recognizance bond, subject to the standard conditions of
release as well as certain special conditions, including: (i) a third-party custodian; (ii) home
detention; (iii) location monitoring; (iv) surrender of his passport; (v) no contact with potential
witnesses or the alleged coconspirators; and (vi) travel restrictions. See Dkt. 14 (Order Setting
Conditions of Release). On motion by the government, Judge Davis stayed Defendant’s release
until August 16, 2023 at 5:00 p.m. See Dkt. 18 (Order Granting Temporary Stay). On August 16,
2023, this Court issued an order staying Defendant’s release pending a hearing on the
government’s motion to revoke Judge Davis’ Order Setting Conditions of Release. Dkt. 20. On
August 23, 2023, this Court held a hearing on the government’s appeal of Judge Davis’ Order
Setting Conditions of Release.

II. STANDARD OF REVIEW

18 U.S.C. § 3145(a) allows this Court to revoke a magistrate judge’s release order. It is
uncontested that in doing so, the Court reviews the magistrate judge’s determinations de novo. See e.g.
United States v. Clark, 865 F.2d 1433, 1438 (4th Cir. 1989); United States v. Burgess, 2:17-cr-153,

2017 WL 6542939, at *1 (E.D. Va. Dec. 19, 2017).
Case 1:23-mj-00157-IDD-RDA Document 27 Filed 08/23/23 Page 4 of 13 PagelD# 130

Because Defendant is charged with an offense that carries a ten-year mandatory minimum
sentence, a presumption in favor of detention arises. 18 U.S.C. § 3142(e)(3)(A). Once triggered,
the presumption imposes a limited burden of production on the defendant to come forward with
some evidence that he does not pose a danger to the community or a risk of flight. United States
v. Khusanov, 731 F. App’x 19, 21 (2d Cir. 2018). When a defendant meets his burden of
production, that “does not eliminate the presumption favoring detention.” Jd. If the defendant
meets his burden of production, the burden shifts to the government. When risk of flight is the basis
for detention, “the government must prove by a preponderance of the evidence that no combination of
conditions will reasonably assure the defendant’s presence at future court proceedings.” United States
v. Stewart, 19 F. App’x 46, 48 (4th Cir. 2001) (per curiam) (citing United States v. Hazime, 762 F.2d
34, 37 (6th Cir. 1985)). When the safety of the community is the basis for detention, the government
must prove dangerousness by clear and convincing evidence. 18 U.S.C. § 3142(f)(2)(B). The
government need only establish one basis for detention.

Under 18 U.S.C. § 3142(g), the Court must consider four factors:

(1) The nature and circumstances of the offense charged, including whether the offense

is a crime of violence, a violation of section 1591, a Federal crime of terrorism, or

involves a minor victim or a controlled substance, firearm, explosive, or destructive

device; (2) The weight of the evidence against the person; (3) The history and
characteristics of the person, including: The person’s character, physical and mental
condition, family ties, employment, financial resources, length of residence in the
community, community ties, past conduct, history relating to drug or alcohol abuse,
criminal history, and record concerning appearance at court proceedings; and whether,
at the time of the current offense or arrest, the person was on probation, on parole, or
on other release pending trial, sentencing, appeal, or completion of sentence for an

offense under Federal, State, or local law; and (4) The nature and seriousness of the
danger to any person or the community that would be posed by the person’s release.

18 U.S.C. § 3142(g)(1)-(4).
II. ANALYSIS
In this case, there is a presumption of detention and, therefore, the initial burden is on
Defendant to come forward with some evidence that he is both not a danger to the community and

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not a risk of flight. Defendant argues that he has “met his burden of production with the proposal
that he be released into the custody of his proposed third-party custodian, Ms. Breannah Worthy,
and placed on home detention with location monitoring.” Dkt. 23 at 4. The government argues
both that Defendant has not overcome the presumption in favor of detention and that Defendant
represents a danger to the community and a risk of flight.

A. Defendant Has Not Overcome the Presumption of Dangerousness

Defendant relies on the imposition of home detention and a third-party custodian to
overcome the presumption of detention. Dkt. 23 at 4. Those conditions may successfully rebut
the presumption as to risk of flight, but those conditions do not limit the danger that Defendant
presents to the community, especially where it is alleged that most of Defendant’s drug trafficking
activity was done by electronic means and through the U.S. mail.

Defendant appears to assume that because his offense is nonviolent it is therefore not
dangerous. Not so. As judges within this District have recognized “the fact that Defendant is
charged with a nonviolent offense is not enough, standing alone, to rebut that he is a danger to
society.” United States v. King, 2020 WL 1915241, at *4 (E.D. Va. Apr. 20, 2020). Moreover,
courts recognize that “[f]entanyl distribution poses a grave danger to the community.” United
States v. Texeira-Spencer, 2021 WL 1535309, at *4 (D.D.C. Apr. 19, 2021); see also United States
v. Gibson, 481 F. Supp. 2d 419, 423 (W.D. Pa. 2007) (“The court must also consider the danger
of trafficking in illicit drugs. When determining whether to detain defendant the court must, in
essence, make a prediction as to whether defendant is likely to traffic in illicit drugs if released
pending trial based on, inter alia, the factors prescribed by the Bail Reform Act.”).

Moreover, the suggested conditions of release do not ameliorate the danger that Defendant
will continue trafficking drugs. This especially true where Defendant’s role in the alleged drug

conspiracy was facilitated primarily by the U.S. mail and electronic means. See United States v.
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Elliott, 546 F. Supp. 2d 643, 645 (S.D. Ind. 2008) (noting that “travel restrictions or a curfew
would be meaningless in the face of a telecommunications network with associates that allows
drug trafficking to continue from remote locations”). Defendant has introduced no evidence that
would satisfy his burden of production with respect to dangerousness. On the other hand, the
government has offered evidence showing that Defendant has no verifiable sources of income, has
a drug problem, is involved in trafficking large quantities of illegal drugs, and was not fully truthful
with pretrial services.2 The government also proffers that Defendant evinced his commitment to
drug trafficking when Defendant continued to engage in drug trafficking after three of his alleged
coconspirators were arrested. See Dkt. 19 ¥ 12 (discussing events indicating a likelihood that law
enforcement was scrutinizing Defendant’s alleged activities). Importantly, Defendant concealed
his travel to Mexico from pretrial services and, even in his Opposition brief, Defendant did not
admit to all of the travel to Mexico of which the government is aware. Moreover, at the August
23, 2023 hearing, the government proffered that text messages from Defendant indicate that
Mexico is connected to Defendant’s alleged drug trafficking and proffered evidence that
Defendant’s explanation for his travel to Mexico — for leisure — is not accurate. The government
also proffered that Defendant is the highest-ranking member of the conspiracy to be arrested.
Thus, Defendant has not rebutted the presumption as to dangerousness and detention is
appropriate. See United States v. Reuben, 974 F.2d 580, 587 (5th Cir. 1992) (reversing order of
release, in a presumption case, where the defendants “‘presented absolutely no evidence whatsoever

to indicate that they will not continue to engage in drug trafficking if released on bail pending

? The government has proffered evidence that Defendant made misrepresentations to pretrial services
regarding: (i) his international travel, because Defendant did not originally report his travel to Mexico; (ii) his travel
documents, because Defendant did not originally report or turn over his U.S. Passport Card or his Jamaican passport;
and (iii) his income, because Defendant did not account for large deposits to his bank accounts beyond the funds he
reported to pretrial services.

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trial”). Accordingly, the government’s motion will be granted, and the Order Setting Conditions
of Release shall be revoked.
B. The Government Has Established that Defendant is a Risk of Flight

The government has established that Defendant is a risk of flight by a preponderance of

the evidence based on the § 3142(g) factors. The Court will address each factor in turn.
1. The Nature and Circumstances of the Offense

Here, Defendant is charged with a very serious drug offense; namely, conspiracy to
distribute 400 grams or more of a substance containing fentanyl. The parties agree that, if
convicted, Defendant is subject to a 10-year mandatory minimum sentence. Under similar
circumstances, judges within this District have found “the penalties at stake in this case provide a
strong incentive to flee.” United States v. Maitland, 2020 WL 1929133 (E.D. Va. Apr. 21, 2020).
Defendant asserts that he is safety valve eligible, such that the seriousness of the penalties is
reduced. Dkt. 23 at 7. But courts do not place heavy reliance on the availability of the safety valve
in making such determinations. See United States v. Martinez-Espinoza, 2020 WL 2767520, at *2
& n.1 (S.D. Cal. May 28, 2020) (noting that there is “no determination whether the Defendant is
safety valve eligible” and that, even with a safety valve, a “defendant with the drug amounts
involved in this case is facing a significant Sentencing Guideline range, which is enough to elevate
the risk of flight”).? Moreover, this is a drug case where, after the arrest of three coconspirators,
Defendant changed his practices in an attempt to evade law enforcement and to continue selling
drugs. See United States v. Portz, 2020 WL 1862364, at *4 (D. Minn. Apr. 14, 2020) (finding

defendant to be a risk of flight based, in part, on his efforts to evade law enforcement detection

3 The government disputes that the safety valve applies because Defendant appears to be a manager or
organizer and because Defendant has firearms that may be connected to the conspiracy.

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and the extent of his drug trafficking ties). Thus, the potential penalties at issue in this case elevate
the risk of flight.
2. The Weight of the Evidence

Defendant argues that the weight of the evidence is among the “least important criteria”
for purposes of detention. Dkt. 23 at 7. There is a split among courts about the weight to be placed
on this factor. Comp. United States v. English, 629 F.3d 311, 317 (2d Cir. 2011) (affirming
detention order which observed that the weight of the evidence “is one of the most important
factors”) with United States v. Gebro, 948 F.2d 1118, 1121 (9th Cir. 1991) (finding the weight of
the evidence to be the least important factor). There is no Fourth Circuit authority on this point.
This Court joins with the only other district judge within this Circuit that appears to have addressed
the issue and will consider this factor and weigh it equally along with all of the other factors. See
United States v. Shaheed, 455 F. Supp. 3d 225, 232 (D. Md. 2020) (“Here, the Court considers it
and weighs it along with the other Bail Reform Act factors.”).

In the instant case, the government’s evidence appears to be strong, which increases the
risk of flight. Defendant incorrectly characterizes the government’s evidence as limited to the pills
seized during his arrest. To that end, Defendant argues that only a small number of pills were
visible at the time of arrest. Defendant may have a point if that were all of the government’s
evidence. The government, however, also put on the testimony of Special Agent Drew. Special
Agent Drew testified at the detention hearing that, an alleged coconspirator, identified Defendant
as the source of supply that has been mailing fake oxycodone pills from Arizona to this District.
8.14.23 Hrg. Tr. at 22:14-20. A review of that coconspirator’s cellphone revealed messages with
pictures of what appears to be illegal drugs and messages discussing shipments of packages from
Arizona to this District from a number believed to be used by Defendant. Dkt. 2 914. Defendant

was also observed, via United States Postal Services (“USPS”) security footage mail, mailing a
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package that was later intercepted and determined to contain over a kilogram of fake oxycodone
pills. 8.14.23 Hrg. Tr. at 15:3-16:1. Defendant was also observed, via USPS security footage,
mailing other packages from Arizona to the various residences in Northern Virginia where other
coconspirators resided and where law enforcement was making controlled drug purchases. Dkt. 2.
Thus, the government has strong evidence of Defendant’s role in the conspiracy.

This evidence of Defendant’s specific involvement in the conspiracy is combined with the
government’s evidence of the conspiracy overall, which includes a great deal of information
gathered through surveillance, confidential informants, and other alleged coconspirators. Dkt. 2;
United States v. Boccone, 556 F. App’x 215, 244 (4th Cir. 2014) (holding, in the context of a drug
conspiracy, a “defendant is responsible not only for his own acts, but also for ‘all reasonably
foreseeable acts’ of his co-conspirators”). Indeed, Defendant recognizes that the evidence against
other alleged members of the conspiracy is “quite strong.” Dkt. 23 at 8. Additionally, not only
does the government have evidence tying Defendant’s alleged coconspirators in Northern Virginia
to the conspiracy and to the drugs, but the government also has evidence tying Defendant’s
girlfriend’ in Arizona to packages sent from Arizona to Northern Virginia as part of the conspiracy.
Dkt. 2 | 30. Until two months ago, Defendant resided with that girlfriend in Arizona and she was
in frequent contact with Defendant. See id. This evidence of the general conspiracy further
supports a risk of flight. See United States v. Berkun, 392 F. App’x 901, 903 (2d Cir. 2010) (noting
that when “the evidence of guilt is strong, it provides” a defendant “with an incentive to flee”).

3. History and Characteristics
Defendant emphasizes that he has no criminal history and that he has presented a third-

party custodian with no criminal history. Dkt. 23 at 8. His Opposition, however, glosses over three

‘ There was a suggestion that the girlfriend in Arizona is now a former girlfriend and that Defendant’s new
girlfriend is the proposed third-party custodian, Ms. Worthy.

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important considerations which cause this factor to weigh in favor of detention: (i) Defendant’s
lack of ties to the United States; (ii) Defendant’s lack of candor with pretrial services; and (iii) the
effectiveness of a third-party custodian.

Defendant has no family members in the United States. Nor does Defendant have close
community ties to Phoenix, Arizona. Defendant has only lived in his current residence for two
months and he could not confirm either his address or the amount of his rent for pretrial services.
Indeed, Defendant’s most significant tie in the United States appears to be his girlfriend, who is
also alleged to be a member of the drug conspiracy. Moreover, Defendant has extensive ties
abroad. His father and four sisters, with whom Defendant reports he is close, are in Jamaica.
Defendant also has brothers in Jamaica and Japan. These facts elevate Defendant’s risk of flight.
See United States v. Vasquez Molina, 588 F. Supp. 2d 1, 2 (D.D.C. 2008) (ordering defendant
detained where, “[t]he defendant has no prior criminal history but has no ties to the United States”).
Additionally, as the government correctly notes, location monitoring only reduces a defendant’s
“head start should a defendant decide to flee” because the ankle monitor can be removed. United
States v. Wang, 2023 WL 4551637, at *3 (S.D.N.Y. July 14, 2023).

Not only does Defendant have no ties to the United States and extensive ties abroad, but
Defendant made misrepresentations about his travel abroad, his resources, and his travel
documentation to pretrial services. Defendant represented to pretrial services that his only travel
in the past 10 years was to Jamaica for his mother’s funeral. Contrary to the Pretrial Services
Report, Special Agent Drew testified, and Defendant’s Opposition now admits, that Defendant has
traveled to Mexico. Comp. Dkt. 9 (“The defendant reported he possesses a valid U.S. passport
located at his residence and stated within the last 10 years he traveled to Jamaica for his mother’s
funeral.”) with 8.14.23 Hrg. Tr. at 17:12-18 (discussing Defendant’s crossings into Mexico); Dkt.

23 (“It is true that Mr. Mitchell vacationed in Mexico at a popular tourist spot ...”). The
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government proffers that it has evidence of multiple such border crossings. Dkt. 19 at 9. Equally
troubling, Defendant misrepresented his travel documentation. Defendant failed to inform pretrial
services that he has a U.S. Passport Card or a Jamaican Passport until after the government filed
its Motion. Defendant did not address his lack of candor in his Opposition. This lack of candor
to pretrial services, and by extension to the Court, are troubling and raise issues about supervision
where Defendant is being deceptive. See United States v. Maxwell, 510 F. Supp. 3d 165, 175
(S.D.N.Y. 2020) (“Most notably, the Defendant’s pattern of providing incomplete or erroneous
information to the Court or to Pretrial Services bears significantly on the Court’s application of
the third factor to the present case.”).

Although it is admirable that Ms. Worthy has volunteered to act as a third-party custodian
for Defendant, there are concerns about whether her acting in that capacity would dissuade
Defendant from absconding. Ms. Worthy is a friend of three years but did not know Defendant’s
current address. Pretrial services reports that Ms. Worthy did not refuse to provide a cash bond
but cannot afford to do so. But the lack of direct consequences to Ms. Worthy, if Defendant
absconds, decreases the “moral suasion” that a third-party custodian is intended to provide. United
States v. Batista, 163 F. Supp. 2d 222, 224 (S.D.N.Y. 2001). Moreover, Ms. Worthy, who
acknowledges that Defendant has a drug problem, appears to lack influence over Defendant. See
id. It is also unclear whether Ms. Worthy, who has not appeared and been examined before the
Court, would have the ability to identify problematic behaviors to report them to pretrial services
or to the Court. See United States v. Bryant, 2022 WL 413962, at *4 (S.D. W.Va. Feb. 9, 2022)
(noting that the fact that the proposed third-party custodian was unaware of the defendant’s
charged criminal activities “could suggest that she would be unable to identify the presence of
drug activity within the home”). Initially, it was unclear to the Court why Ms. Worthy was offering

to be a third-party custodian, but, at the August 23, 2023, defense counsel revealed that Ms. Worthy
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is aromantic partner. It is commendable that Ms. Worthy would offer to be a third-party custodian,
but that does not mean that she is the kind of third-party custodian who can exert influence over
and monitor Defendant. Thus, this element also weighs against release.>
IV. CONCLUSION

The presumption of detention and an analysis of the § 3142(g) factors compel the
conclusion that Defendant should be detained pending trial. In sum, the government has presented
compelling evidence that Defendant engaged in drug trafficking, that Defendant has a drug
problem that would incentivize him to continue seeking drugs, that his most serious tie to the
United States — his girlfriend — is also involved in drug trafficking, that he has had no steady
employment,® that he has extensive ties abroad, and that he made misrepresentations to pretrial
services. Defendant has failed to rebut the presumption of dangerousness applicable in this case.
Moreover, the government has established by a preponderance of the evidence that he is a risk of
flight and no conditions or combination of conditions would ensure his appearance. Because
Defendant presents both a risk of flight and a danger to the community, Defendant should not be
released pending trial.

Accordingly, for the foregoing reasons, it is hereby ORDERED that the government’s
motion (Dkt. 19) is GRANTED; and it is

FURTHER ORDERED that Judge Davis’ Order Setting Conditions of Release (Dkt. 14)

is hereby REVOKED; and it is

5 The fourth factor deals more directly with risk of dangerousness. Because the Court has already determined
that Defendant has not rebutted the presumption of dangerousness and because this analysis focuses on risk of flight,
this factor need not be addressed.

6 At the August 23, 2023 hearing, defense counsel proffered that Defendant has an offer of employment with
arestaurant in Phoenix. But this does not assuage the Court’s concern that Defendant has not had steady employment
in the past and that his prior sources of income are unverifiable.

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FURTHER ORDERED that Defendant Aaron Alex Mitchell shall be detained pending
trial.
It is SO ORDERED.

Alexandria, Virginia
August 2 2023

/s/
Rossie D, Alston, Jr.
United States District Judge

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